Regulations Amending the Immigration and Refugee Protection Regulations (Administrative Penalties and Consequences): SOR/2026-220

Canada Gazette, Part II, Volume 160, Number 22

Registration
SOR/2026-220 October 23, 2026

IMMIGRATION AND REFUGEE PROTECTION ACT

P.C. 2026-1007 October 23, 2026

Her Excellency the Governor General in Council, on the recommendation of the Minister of Citizenship and Immigration, makes the annexed Regulations Amending the Immigration and Refugee Protection Regulations (Administrative Penalties and Consequences) under subsections 5(1) and 91.1(1)footnote a and (2)footnote b of the Immigration and Refugee Protection Actfootnote c.

Regulations Amending the Immigration and Refugee Protection Regulations (Administrative Penalties and Consequences)

Amendment

1 The Immigration and Refugee Protection Regulationsfootnote 1 are amended by adding the following after section 315.43:

PART 19.2
System of Administrative Penalties and Consequences — Representation and Advice

Interpretation

Definition of reviewer

315.44 In this Part, reviewer means a person appointed by order under subsection 91.1(3) of the Act.

Purpose

Purpose

315.45 The purpose of the administrative penalties and consequences provided for in this Part is to encourage compliance with the provisions of the Act and these Regulations and not to punish.

Violations

Designation

315.46 The contravention, including a contravention committed outside Canada, of any of the following provisions is designated as a violation:

Prohibitions

Unauthorized practice

315.47 A person must not knowingly, directly or indirectly, represent or advise a person for consideration — or offer to do so — in connection with the submission of an expression of interest under subsection 10.1(3) of the Act or a proceeding or application under the Act unless they are a person or entity referred to in any of subsections 91(2) to (4) of the Act.

Misrepresentation

315.48 A person who, directly or indirectly, represents or advises a person for consideration — or offers to do so — in connection with the submission of an expression of interest under subsection 10.1(3) of the Act or a proceeding or application under the Act must not knowingly

Inspection

Inspection

315.49 (1) If an officer has reasonable grounds to suspect that a person has committed a violation, the officer may conduct any inspection that they consider to be necessary to verify that the person is in compliance with sections 315.47 and 315.48, including the inspection of any entity for which that person conducts business relating to the provision of immigration and citizenship representation and advice.

Inspection of documents

(2) When conducting an inspection under subsection (1), an officer may, in writing, require the person or entity to provide any relevant document.

Requirement to provide documents

(3) Subject to subsections (4) and (5), the person or entity that is required by an officer to provide documents must provide them within the period and in the manner specified by the officer.

Affidavit — person

(4) A person referred to in paragraph 91(2)(a) or subsection 91(3) of the Act is not required to provide the documents if that person, within the period specified by the officer, submits an affidavit attesting that the documents contain information that is subject to litigation privilege, solicitor-client privilege or the professional secrecy of advocates and notaries.

Affidavit — entity

(5) An entity is not required to provide documents in respect of a person referred to in paragraph 91(2)(a) or subsection 91(3) of the Act if that entity, within the period specified by the officer, submits an affidavit attesting that the documents contain information that is subject to litigation privilege, solicitor-client privilege or the professional secrecy of advocates and notaries.

Justification

(6) A failure to comply with subsection (3) is justified if the person or entity made all reasonable efforts to comply or if the failure results from anything done or omitted to be done by the person or entity in good faith.

Preliminary Notice

Preliminary notice

315.5 (1) An officer who, on the basis of information obtained by any officer in the exercise of the powers set out in section 315.49 and of any other relevant information, believes on reasonable grounds that a person has committed a violation may provide that person with written notice to that effect.

Preliminary notice — contents

(2) The preliminary notice must list all violations identified in the course of the inspection conducted under subsection 315.49(1) and must indicate

Submissions

315.51 (1) A person to whom a preliminary notice is sent under subsection 315.5(1) may, within 30 days after the date of receipt of the notice,

Deemed receipt

(2) Despite subsection 9.3(2), a preliminary notice is deemed to have been received 30 days after the day on which it is sent.

Extension of period

(3) An officer may extend the 30-day period set out in subsection (1) if there is a reasonable justification for the extension.

Notice of Violation

Notice of violation

315.52 (1) Subject to subsections (2) and (3), an officer who, on the basis of information obtained by any officer in the exercise of the powers set out in section 315.49 and of any other relevant information, determines on a balance of probabilities that a person has committed a violation may issue a notice of violation to them.

Period

(2) An officer must not issue a notice of violation unless a preliminary notice was sent to the person under subsection 315.5(1) and the 30-day period set out in subsection 315.51(1) or the period extended under subsection 315.51(3), as the case may be, has expired.

Affidavit

(3) An officer must not issue a notice of violation to a person who submits an affidavit under paragraph 315.51(1)(b), unless the person has withdrawn their attestation in writing.

Notice of violation — contents

(4) The notice of violation must list all violations for which a determination has been made under subsection (1) and must indicate

Deemed receipt

(5) Despite subsection 9.3(2), a notice of violation is deemed to have been received 30 days after the day on which it is sent.

No further administrative monetary penalty

315.53 (1) Once a notice of violation is issued to a person, no further administrative monetary penalties may be imposed on that person under this Part with respect to any acts or omissions that occurred before the date of issuance of that notice of violation.

Citizenship Regulations

(2) If a notice of violation is issued to a person under subsection 41(1) of the Citizenship Regulations, no administrative monetary penalties may be imposed on that person under this Part with respect to any acts or omissions that occurred before the date of issuance of that notice of violation, unless they are set out in a notice of violation that is issued under subsection 315.52(1) on that same date.

Administrative Monetary Penalty

Calculation of penalty

315.54 (1) The administrative monetary penalty for a violation in respect of any of section 315.47 and paragraphs 315.48(a) to (c) is determined by the formula

(A + B + C) Ă— D
where
A
is the applicable baseline penalty set out in subsection (2);
B
is the amount, if any, related to the impact of the violation as set out in subsection (3);
C
is the financial advantage amount, if any, determined under subsection (4); and
D
is the multiplier for prior violations, as determined under subsection (5).

Baseline penalty

(2) The baseline penalty is the following:

Impact of violation

(3) If an error in the administration of the Act results from a violation in respect of any of paragraphs 315.48(a) to (c), the amount related to the impact of the violation is $15,000.

Financial advantage

(4) If the person who is believed to have committed the violation derives a financial advantage from the violation, the financial advantage amount is equal to the total of any amounts that they received in connection with the violation.

Prior violations

(5) The multiplier for prior violations is

Calculation of administrative monetary penalty — inspection

315.55 (1) The administrative monetary penalty for a violation in respect of subsection 315.49(3) is $10,000 multiplied by the multiplier for prior violations, as determined under subsection 315.54(5).

Clarification

(2) A failure to comply with subsection 315.49(3) on more than one occasion in the course of an inspection conducted under subsection 315.49(1) results in one administrative monetary penalty only.

Maximum amount

315.56 (1) If a notice of violation lists more than one violation and the total of the administrative monetary penalties exceeds $1.5 million, the total must be reduced by the excess amount.

Cumulative amounts

(2) If a notice of violation is issued on the same date as a notice of violation issued under subsection 41(1) of the Citizenship Regulations, the administrative monetary penalties set out in the two notices are cumulative, but the total must not exceed $1.5 million.

Payment

Payment

315.57 (1) Subject to section 315.58, the administrative monetary penalties that are assessed under this Part must be paid within 30 days after the date of receipt of the notice of violation unless the person to whom the notice is issued enters into an agreement with the Minister with respect to payment within those 30 days.

Deeming

(2) If the person pays the administrative monetary penalties or enters into an agreement with the Minister in accordance with subsection (1), the person is deemed to have committed the violations.

Review

Request for review

315.58 (1) A person to whom a notice of violation is issued may, instead of paying the administrative monetary penalties, request in writing, within 30 days after the date of receipt of the notice, a review of the notice of violation or of the penalties, or of both.

Grounds

(2) The request must include the grounds on which it is based but must not include new evidence.

Deeming

(3) If the person does not make a request in the time and manner set out in subsection (1), the person is deemed to have committed the violations.

Review

315.59 (1) In respect of each violation under review, a reviewer must determine, on a balance of probabilities, whether the person who requests the review committed the violation and, if so, whether the administrative monetary penalty has been determined in accordance with this Part.

Violation not committed — effect

(2) If the reviewer determines that the person did not commit the violation, the reviewer must cancel the administrative monetary penalty.

Violation committed — penalty

(3) If the reviewer determines that the person committed the violation, the reviewer must verify that the administrative monetary penalty was determined in accordance with this Part and

Decision on completion of review

(4) On completion of the review, the reviewer must confirm, amend or cancel the notice of violation by issuing to the person a notice of decision.

Notice of decision — contents

(5) The notice of decision must list all violations for which a determination under this section has been made and must indicate

Deemed receipt

(6) Despite subsection 9.3(2), the notice of decision is deemed to have been received 30 days after the day on which it is sent.

Obligation to pay

(7) The person must pay the administrative monetary penalties that are set out in the notice of decision within 30 days after the date of receipt of the notice unless they enter into an agreement with the Minister with respect to payment within those 30 days.

Consequences

Publication

315.6 (1) Subject to subsection (2), the Minister must publish the following information on the Department’s website with respect to each person who has been deemed, or determined by a reviewer, to have committed a violation referred to in section 315.46:

Time period

(2) The Minister must not publish the information before the end of the period set out in subsection 315.58(1).

Coming into Force

2 These Regulations come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues: Individuals seeking to immigrate to Canada or become Canadian citizens often rely on the advice and expertise of other people to help them navigate immigration and citizenship processes and applications. When these individuals commit infractions, such as providing advice and representation for remuneration without statutory authorization or counselling fraud and misrepresentation on their clients’ applications, it undermines the integrity of Canada’s immigration and citizenship systems. It can also cause serious harm to clients, especially vulnerable individuals who face language or cultural barriers. Currently, Immigration, Refugees and Citizenship Canada (IRCC) lacks effective tools to deter these unauthorized and harmful practices.

Description: The Regulations Amending the Immigration and Refugee Protection Regulations and the Citizenship Regulations (Administrative Penalties and Consequences) – herein referred to as “the Amendments” – establish a new system of administrative penalties and consequences to address unauthorized practice and misrepresentation in immigration and citizenship services. This includes giving IRCC officers authority to investigate suspected violations, to issue preliminary notices and notices of violations, and to impose monetary penalties and consequences on individuals who engage in unauthorized practice or who misrepresent in immigration or citizenship services. The system introduces clear penalties, a review process, and public disclosure of violators.

Rationale: The Amendments address long-standing gaps in Canada’s immigration and citizenship systems by providing IRCC with a new enforcement tool to deter unauthorized practice and misrepresentation. To promote fairness and accountability, the regime also includes procedural safeguards such as an independent review process and protections for solicitor-client privilege.

The Amendments are estimated to cost the Government of Canada $13,826,575 present value (PV) over 10 periods of 12 months to implement and operate the regime. The Amendments are expected to deliver significant benefits, including improved compliance with immigration and citizenship laws, reduced fraud in the immigration and citizenship system, increased public confidence in Canada’s immigration and citizenship system, and better protection for applicants. These benefits were not monetized.

Issues

Individuals seeking to immigrate to Canada or become Canadian citizens often rely on the advice and expertise of other people to help them navigate immigration and citizenship processes and applications. Individuals committing infractions such as providing advice and representation for remuneration without statutory authorization or counselling fraud and misrepresentation on their clients’ applications has a negative effect on the integrity of Canada’s immigration and citizenship systems. The impacts on clients of such infractions, which can include financial loss, process delays, application refusals and legal consequences, can be egregious, particularly when the victims are vulnerable due to language and cultural barriers. Under the existing regulatory framework, Immigration, Refugees and Citizenship Canada (IRCC) lacks effective tools to deter these unauthorized and harmful practices.

Background

Only authorized immigration and citizenship practitioners are permitted to provide advice and representation for payment on immigration and citizenship-related matters. Authorized practitioners include members in good standing of one of the following groups: the College of Immigration and Citizenship Consultants (the College), a provincial or territorial law society, or the Chambre des notaires du Québec. These practitioners are authorized to provide services such as explaining immigration and citizenship options, advising as to the most appropriate programs, assisting in the completion of applications and communicating with IRCC on behalf of clients. Their specialized expertise allows them to help applicants navigate Canada’s immigration and citizenship processes and ensure applicants meet the requirements.

According to the College’s 2025 Annual Report, there were 12 501 licensees of the College. All lawyers and Quebec notaries are authorized to provide immigration and citizenship advice and representation, though many practice in other unrelated areas. Authorized practitioners receive specialized training and are effectively regulated, meaning that they are held to a high standard of practice and there are options for complaints and potential recourse through their professional regulators should they not meet those standards.

In addition to licensed practitioners, there is an unknown number of unauthorized individuals both in and outside Canada who provide paid immigration and citizenship advice and representation, despite not being legally permitted to do so. Unauthorized individuals are a problem in the current immigration and citizenship system and solutions are needed to help deter their actions. For example, an average of 282 leads of suspected immigration practitioner offences are brought to the attention of the Canada Border Services Agency (CBSA) annually and of these, an average of 50 (17%) involve alleged unauthorized individuals. On average, a quarter of charges laid annually are against those who are not authorized to provide immigration and citizenship consultant servicesfootnote 2.

Despite existing professional discipline measures and criminal penalties, clients continue to face issues like fraud in applications and documents. These may have dire consequences for applicants, including refusal of citizenship or immigration applications, financial hardship, losing legal immigration status in Canada or revocation of Canadian citizenship.

In June 2017, the House of Commons Standing Committee on Citizenship and Immigration (CIMM) published a report entitled Starting Again: Improving Government Oversight of Immigration Consultants. CIMM studied the framework governing immigration and citizenship consultants and found it inadequate. The Committee made 21 recommendations focusing on three areas of concern: 1) weakness in governance; 2) insufficient resources for investigations and enforcement; and 3) lack of public awareness and the need to better serve clients.

In response to these persistent issues and the CIMM recommendations, the Immigration and Refugee Protection Act (IRPA) and the Citizenship Act (CA) were amended in 2019 to allow the establishment of an Administrative Penalties and Consequences (APC) regime by regulation. This initiative aims to enable IRCC to directly respond to and impose a penalty or consequence on those who commit violations while providing paid immigration and citizenship advice. Establishing an APC regime is a crucial step towards enhancing the integrity of the immigration system and more effectively safeguarding the interests of those seeking to navigate it.

Objective

The objectives of the Regulations Amending the Immigration and Refugee Protection Regulations and the Citizenship Regulations (Administrative Penalties and Consequences) herein referred to as “the Amendments” are to

The expected outcomes of the Amendments are to

Description

The Amendments establish an administrative penalties and consequences regime under the CA and IRPA.

Violations

The Amendments prohibit a person from providing or offering to provide representation for payment unless they are authorized to do so under the CA or IRPA.

The Amendments prohibit a person who represents or advises someone for payment from misrepresenting or withholding information, advising them to misrepresent or withhold information, or communicate misleading information.

The Amendments designate unauthorized practice and misrepresentation as violations.

Inspections

The Amendments provide IRCC officers the authority to require, in writing, that a person or entity provide any relevant documents to verify compliance in circumstances where the officer has reasonable grounds to believe they have committed a violation. If the individual fails to submit relevant documents, the failure would be justified if the individual made reasonable efforts to comply. Additionally, failure to comply with a document request is justified if the individual has submitted an affidavit affirming that they cannot respond due to solicitor-client privilege.

Preliminary notice

The Amendments authorize an IRCC officer who has reasonable grounds to believe that a person committed a violation to issue a preliminary notice to the individual.

The notice is required to include

Additionally, the Amendments include a safeguard to avoid situations where legal professionals, including lawyers and notaries, may be unable to adequately respond to a preliminary notice or request for document inspection without breaching solicitor-client privilege. In such cases, counsel may submit an affidavit attesting both that relevant information or material remains subject to solicitor-client privilege and that they are unable to adequately defend themselves without disclosing privileged information. Upon receipt of such an affidavit, IRCC will discontinue that particular APC investigation or process.

Notice of violation

Following the issuance of a preliminary notice and after having reviewed any information submitted in response, the Amendments authorize an IRCC officer to issue a Notice of Violation (NOV) if they determine, on a balance of probabilities, that a person committed a violation.

The Amendments set out the information that must be included in the NOV, including, for example, information about the violation and the amount of the penalty.

The Amendments provide that no administrative monetary penalty may be imposed in respect of any acts or omissions, other than those that are the subject of the NOV, that occurred before the date on which the person’s most recent NOV was issued.

Additionally, the Amendments require that a preliminary notice be issued before the NOV and that officers issue just one NOV if the evidence shows violations under both the Immigration and Refugee Protection Regulations (IRPR) and the Citizenship Regulations (CR). If a person asserts by affidavit that they cannot respond due to solicitor-client privilege, then the NOV would not be issued.

Administrative monetary penalties and amounts

The Amendments introduce a formula and baseline penalty amounts to be used when calculating the administrative monetary penalty for unauthorized practice and misrepresentation:

Administrative monetary penalty = (A + B + C) Ă— D
Where:
A
is the baseline penalty amount, which is determined depending on the type of violation:
  • Representation or advice without authorization: $5,000
  • Misrepresentation: $15,000
B
is the amount added when a misrepresentation violation had an additional impact by inducing an error in the administration of the relevant Act by causing an application to be approved when it otherwise would not have been. The Amendments specify that misrepresentation violations include communicating false or misleading information or declarations with the intent to induce or deter immigration to Canada.
  • Additional impact amount: $15,000
C
is the financial advantage gained as a result of the violation:
  • If an individual gained a financial advantage as a result of committing a violation (e.g. any money that they were paid by a client to provide unauthorized advice or to assist with misrepresentation), this amount is included in the penalty amount.
D
considers the individual’s previous history with the regime. Specifically,
  • if the person has not previously been issued an NOV, the penalty amount would be multiplied by 0.5 (halved);
  • if the person has, on one previous occasion, been issued an NOV under either the IRPR or the CR, the penalty amount would be multiplied by 1; and
  • if the person has been issued a combined total of two or more NOVs under the IRPR and CR, the penalty amount would be multiplied by 1.5.
Failure to comply with an inspection

The Amendments establish the penalty for an individual who does not comply with a request for submission of relevant documents by an officer to verify compliance at $10,000, multiplied by the factor in element D of the formula for determining the penalty amount for other violations. A failure to comply on more than one occasion in the course of an inspection would result in one administrative monetary penalty.

Maximum amount per NOV

The Amendments specify that if an NOV includes multiple violations, the penalties are cumulative and the total amount for all violations could not be more than $1,500,000.

Payment

The Amendments require that an administrative monetary penalty be paid within 30 days after receipt of the NOV, unless the person has entered into an agreement with the Minister with respect to payment within 30 days.

Review

The Amendments allow a person who received an NOV to make a written request, within 30 days of receipt of the notice, for a review of the facts of the violation or of the amount of the penalty, or both, instead of paying the administrative monetary penalty. As per IRPA and the CA, the review would be conducted by a reviewer appointed by the Governor in Council for that purpose.

The Amendments require that the reviewer determine whether the person was liable for the violation and the amount of the penalty, based on the information that was available to the officer who issued the notice. The Amendments would not allow the reviewer to consider new evidence.

Based on the findings of their review, the Amendments require the reviewer to cancel, confirm, or amend the NOV, and to state, in writing, the reasons for their decision. Upon completion of this review, a Notice of Decision letter will be issued.

The Amendments require that the person pay any penalty set out in the Notice of Decision within 30 days, unless they enter into an agreement with the Minister.

The Amendments enable individuals who receive an NOV to identify and address errors in IRCC’s findings during the review process. This means that while they cannot introduce new evidence, individuals can point out mistakes or inaccuracies in the original decision made by IRCC.

Consequences

The Amendments require that the Minister publish information concerning persons found liable for a violation on IRCC’s website, including

Regulatory development

Consultation

IRCC consulted with the CBSA and the Royal Canadian Mounted Police (RCMP) on the proposed regulatory amendments, and they did not express any concerns. Their mandates would be impacted as they investigate and prosecute those who commit immigration and citizenship fraud under IRPA and the CA as well. Primary responsibility for IRPA criminal investigations belongs to the CBSA, and CA investigations to the RCMP.

The Federation of Law Societies of Canada was consulted in August 2024 regarding the high-level concepts of the proposed APC regime. Following the prepublication period, the Federation of Law Societies of Canada was consulted on proposed changes that would allow licensed legal professionals to assert privilege by affidavit in response to a request for documents or a Preliminary Notice. The Federation maintained that licensed legal professionals should be excluded from the application of the regime. It indicated that the proposed changes did not adequately address its concerns regarding solicitor-client privilege, confidentiality, federal encroachment on the regulation of the legal profession, and duplicative regulation, and that the affidavit approach created concerns related to fairness, administrative burden, and delay without corresponding public benefit.

The College was consulted in August 2024 on the high-level concepts and was supportive of the proposed regime. Following prepublication, IRCC consulted the College again on the proposed affidavit provisions. The College provided technical considerations but did not express a position on the proposed changes.

During the prepublication period, IRCC conducted four technical briefings on the proposed Amendments, specifically designed for lawyers and immigration and citizenship consultants. More than 700 participants attended.

Prepublication comments

The regulatory proposal was prepublished in the Canada Gazette, Part I, on December 21, 2024, for a 45-day comment period, ending on February 4, 2025. Comments were received on both the amendments to the IRPR and the CR. Comments on the IRPR and the CR were similar in nature, with most comments focusing on the APC regime in general. Various stakeholders, including provincial and territorial law societies, lawyer and immigration and citizenship consultant associations, individual lawyers and consultants, and other individuals, provided feedback on the proposed Amendments. IRCC also considered comments received via email after the end of the consultation period. IRCC received 231 comments and email submissions. One hundred and nineteen individual comments were provided via the Canada Gazette, and 112 submissions were made via email.

The comments received have helped refine the Amendments, ensuring a balance between fair enforcement, due process, and protection for applicants and practitioners.

About 30% of the comments were positive and 20% were neutral. Supportive feedback emphasized the importance of strengthening the integrity of Canada’s immigration and citizenship systems, with many commenters highlighting the need for stronger enforcement tools to deter unauthorized or unethical representatives. Positive comments also expressed support for increasing transparency, protecting applicants — especially vulnerable individuals — from fraud or exploitation, and holding violators accountable through public disclosure and financial penalties. These respondents generally viewed the APC regime as a necessary and overdue step to reinforce trust in the system.

Half the respondents raised concerns with the proposed Amendments, some of which resulted in changes to the proposed Amendments. These comments are summarized below.

Unauthorized practice and misrepresentation

Comment: Some organizations representing immigration practitioners such as immigration and citizenship consultants and lawyers expressed concerns that the amendments might be too broad in defining what constitutes unauthorized practice and misrepresentation. Specifically, there were worries about penalties being applied to minor violations, which could result in excessive fines for smaller infractions.

Response: The penalties are designed to target serious breaches of the IRPR and the CR using a graduated penalty structure that takes into account the severity and impact of each violation. This system adjusts penalties based on factors such as the nature of the offence (misrepresentation is subject to a greater penalty than unauthorized practice, given its greater negative impact), whether it is a first-time or repeated violation, and the harm caused. The penalty amount is reduced for first-time violators. The Amendments aim to curb fraud and protect clients from exploitation by unauthorized individuals, ensuring that penalties are fair and proportionate to the offence. The definitions of unauthorized practice and misrepresentation align with the wording of existing criminal offences in IRPA and the CA, and are designed to capture intentional offences that would not be considered minor in nature. As a result, no changes were made to the definitions of these offences.

Penalties for misrepresentation

Comment: Lawyers and immigration consultants expressed concerns that the penalties for misrepresentation, particularly the baseline penalty of $15,000, could be too harsh. Some feared that this could lead to significant consequences for small businesses, especially those working with complex cases.

Response: the penalties are meant to act as a deterrent against misrepresentation cases, and a graduated penalty system allows for flexibility based on the nature, frequency, and impact of violations, ensuring penalties are proportionate. Misrepresentation can have severe consequences for clients. Misrepresentation can result in a five-year period of inadmissibility under IRPA, during which the person is not permitted to enter or apply to enter Canada. Under the CA, misrepresentation can also prevent a person from being granted citizenship or taking the oath of citizenship for 5 years. In addition, a person whose citizenship is revoked under subsection 10(1) of the CA for obtaining, retaining, renouncing, or resuming citizenship through misrepresentation is prohibited from reapplying for or being granted citizenship for 10 years. Misrepresentation also has serious negative impacts on the integrity of the immigration and citizenship processes. These potential outcomes justify the need for strong penalties to effectively deter misrepresentation and protect the integrity of Canada’s immigration and citizenship systems. No changes were made to the penalty amounts.

Potential conflict of interest and expanded enforcement authority

Comment: Some lawyers and law associations were concerned that IRCC’s authority to impose penalties and consequences on lawyers who challenge its decisions in court could create a conflict of interest. Others argued that the APC regime significantly expands IRCC’s enforcement powers without sufficient oversight.

Response: The APC regime is designed to ensure compliance with immigration and citizenship laws, specifically targeting fraud and misrepresentation in applications. It does not and cannot be used to penalize lawyers for exercising their right to challenge IRCC decisions in court. The enforcement function of the regime operates separately from IRCC’s application processing role, which helps maintain impartiality and prevents any conflicts of interest. Additionally, the regime includes built-in oversight mechanisms, notably the review process established in the Regulations. This process allows individuals who receive an NOV to request an independent review of the facts and the penalty amount, providing an important layer of accountability and transparency to ensure penalties are applied fairly and appropriately.

Authority to require documents and failure to submit

Comment: Some stakeholders, such as lawyers and immigration and citizenship consultants, raised concerns about the broad authority granted to IRCC officers to request documents from individuals and suggested the penalties for failure to submit documents could be punitive, especially for small businesses. There were concerns that this could lead to potential abuses or that the documents could be requested inappropriately, resulting in unnecessary administrative burdens.

Response: Any request for documents would need to be based on reasonable grounds and individuals will not be penalized if they make reasonable efforts to comply. Penalties would only be imposed when there is a clear failure to comply, and amounts would be calculated based on the prior history of violations, which would allow for more leniency in cases involving first-time violators.

Solicitor-client privilege in document requests

Comment: A key concern raised by several stakeholders, particularly lawyers and legal associations, was the impact of these amendments on solicitor-client privilege. The Amendments allow IRCC officers to request documents to verify compliance, including personal and sensitive information. Legal professionals expressed concerns that this could violate solicitor-client privilege, which protects communications between lawyers and their clients. The concern was that the $10,000 fine could be levied against lawyers who decline to disclose privileged information.

Several lawyers raised concerns about potential violations of sections 7 and 8 of the Canadian Charter of Rights and Freedoms, which protect life, liberty, security, and guard against unreasonable search and seizure. Some feared that IRCC’s inspection powers could infringe upon these rights, particularly in relation to solicitor-client privilege.

Response: In order to protect solicitor-client privilege, the Amendments now provide that a failure to comply with a document request is justified where the individual submits an affidavit confirming that they cannot comply because the requested information or documents are subject to solicitor-client privilege. In such circumstances, counsel may submit an affidavit attesting that relevant information remains privileged and that they are unable to adequately respond without breaching that privilege. Upon receipt of such an affidavit, IRCC would not pursue the APC process for that particular matter.

Concerns about due process

Comment: Lawyers and law associations expressed concern that the issuance of a preliminary notice could suggest guilt before a final decision has been made, potentially harming the reputations of individuals before they have a chance to contest the findings.

Response: The preliminary notice is only a preliminary finding, and is not made public. Individuals have the opportunity to respond before any enforcement action is taken, ensuring procedural fairness.

In response to stakeholder feedback, the regulations have been revised to make two key changes:

Together, these changes address concerns about fairness and perception by emphasizing the preliminary nature of the preliminary notice and reinforcing the individual’s right to respond before any enforcement action is taken.

Formula, penalty amounts and payments

Comment: Concerns were raised by immigration and citizenship consultants that the formula for calculating penalties, particularly with the potential for large penalties, might be too harsh, especially for those who are repeat violators. Some respondents argued that penalties for small businesses and first-time violators should be lower.

Response: The formula provides for a graduated structure, where penalties for first-time violations are reduced, while repeat violators face higher penalties. The goal is to ensure a fair and proportionate response to violations, while protecting the integrity of the immigration and citizenship system by deterring such violations. The formula and amounts are similar to other administrative monetary penalty regimes at the federal and provincial levels.

Comment: The potential for a maximum penalty of $1.5 million per NOV raised significant concerns among small businesses and practitioners, who felt that such high fines could lead to financial hardship.

Response: The maximum penalty amount is applicable to the sum of the penalties associated with each violation covered in a single NOV. To clarify, a person or business would likely need to have committed numerous violations — potentially over 100 — or have profited significantly from acts such as misrepresentation to be issued a maximum penalty of $1.5 million. This maximum penalty is meant to address egregious or repeated non-compliance that causes serious harm to the integrity of the immigration system.

The rationale behind setting the maximum penalty at $1.5 million is to ensure that penalties are sufficient to deter large-scale or intentional wrongdoing. It reflects the need to impose a meaningful financial consequence that corresponds to the scale and severity of the violations, including where significant financial gain has been obtained through dishonest or fraudulent practices.

Comment: Several lawyers and immigration and citizenship consultants expressed concern that the 30-day deadline to pay penalties could be challenging, particularly for small businesses or individuals with limited financial resources.

Response: The Amendments allow for flexible payment arrangements, including the option to enter into an agreement with the Minister if an individual faces financial difficulties. This flexibility is intended to ensure that penalties do not place undue hardship on those who are legitimately trying to comply.

Review process

Comment: Some stakeholders, particularly legal professionals, raised concerns about the fairness and transparency of the review process. They worried that the reviewer, appointed by the Governor in Council, might not be fully independent.

Response: The review process will be impartial with the reviewer operating separately from IRCC. Specifically, the reviewer is appointed by the Governor in Council and functions as an external authority, not as an employee or officer of IRCC. This structural separation ensures that the review process is conducted at arm’s length from IRCC, thereby ensuring objectivity and fairness.

Comment: Lawyers and law associations were concerned with the inability to present new evidence during the review process of an NOV. This issue was emphasized by those who felt that introducing new evidence could either demonstrate their lack of liability or help mitigate the penalties.

Response: While the review is based solely on the evidence available to the officer who issued the NOV, the Regulations have been adjusted to confirm that the recipient of an NOV can identify and flag errors in the original decision to the reviewer without providing new evidence.

Review mechanisms are a common feature of administrative monetary penalty regimes that include a built-in process to challenge or review a penalty decision. However, the ability to introduce new evidence at the review stage is not uniform across such regimes. Based on a review of selected federal administrative monetary penalty regimes, some regimes allow evidence, additional information, or written representations to be submitted at review. These regimes do not include a Preliminary Notice stage before a Notice of Violation is issued. The proposed APC regime is structured differently, as it includes a Preliminary Notice stage before a Notice of Violation may be issued. At that stage, the person has an opportunity to respond to the alleged facts and potential violations, and to provide relevant submissions and supporting information for IRCC’s consideration before a decision is made. The APC review stage is therefore designed as a record-based review rather than a rehearing or continuation of the investigation.

Consequences and public disclosure

Comments: Several stakeholders, such as lawyers and immigration and citizenship consultants, voiced concerns that publicizing the names of violators could cause significant reputational harm, even if the penalty is later overturned. They suggested safeguards to ensure that individuals’ names are removed from public records if a violation is found to be unjustified.

Response: Any published information regarding a notice of violation would be removed if the violation were overturned through judicial review. IRCC also emphasizes that public disclosure serves as both a deterrent and a protection for clients by promoting transparency and accountability within the immigration and citizenship consulting industry. By making violations public, it discourages unethical or unlawful behaviour among practitioners, reducing the risk that clients will be misled or harmed. At the same time, it empowers clients to make informed decisions when choosing representatives, thereby safeguarding their interests and trust in the immigration and citizenship system.

Jurisdiction and regulatory overlap

Comment: Several commenters, including lawyers, provincial and territorial law societies, and lawyer associations, raised concerns regarding IRCC’s jurisdiction over lawyers, who are already regulated by their respective provincial law societies. They argued that IRCC’s involvement could result in inappropriate overlap with provincial regulatory bodies.

Response: While provincial law societies regulate lawyers, the APC regime does not constitute regulation. Instead, IRCC’s authority stems from IRPA and the CA, which grant IRCC federal oversight in matters related to immigration and citizenship. While provincial bodies oversee lawyers’ general professional standards, IRCC’s role is to enforce immigration-specific and citizenship-specific rules and penalties, which are distinct from professional discipline (citizenship is federal jurisdiction, and immigration is a shared federal and provincial/territorial jurisdiction).

Comment: There was a related concern that the Amendments constitute a dual regulation of immigration and citizenship professionals.

Response: The APC regime is separate from, rather than duplicating the regulatory responsibilities of law societies and professional bodies such as the College. While law societies regulate professional conduct, IRCC’s mandate is to ensure compliance with immigration and citizenship laws and regulations, thus providing a necessary layer of enforcement to combat unauthorized practices and fraud in the immigration and citizenship system. It is important to note that the APC regime does not replace or interfere with the disciplinary processes or regulatory frameworks of the College or law societies, and the regime does not have any impact on a lawyer’s right to practise. Instead, it targets violations related directly to immigration and citizenship laws. The regime addresses conduct that affects the integrity of the immigration system and citizenship as a whole. Therefore, the APC regime is not duplicative but rather a distinct and complementary enforcement tool that supports the broader regulatory ecosystem.

Federal court backlog concerns

Comment: Some commenters worried that the APC regime could lead to an increase in litigation, and thereby add pressure to the Federal Court system.

Response: IRCC acknowledges stakeholders’ concerns about the potential for increased litigation and its impact on the Federal Court system. However, IRCC emphasizes that the APC regime is a necessary tool to strengthen enforcement of immigration and citizenship laws and protect the integrity of the immigration and citizenship system. The regime provides an efficient and proportionate mechanism to address violations without relying solely on court processes.

Cost-benefit analysis

Comment: Some stakeholders, such as lawyers and consultants, expressed concerns about the impact of the APC regime on small businesses, particularly as related to the burden it may place on businesses when challenging decisions via review requests.

Response: IRCC acknowledges that individuals and businesses (including small businesses) may incur costs associated with providing evidence against the preliminary notice, and/or requesting a review of their NOV. It is important to note that individuals will be provided the opportunity to respond to the alleged facts and potential violations set out in the preliminary notice before any enforcement action is taken, and before a review can be requested to challenge a decision, ensuring that only well-substantiated cases proceed and get to the stage of a review request. Additionally, costs of a review request would only be considered for the purposes of the cost-benefit analysis where a review is undertaken and the penalty is overturned. Otherwise, review request costs do not have standing for the purpose of the cost-benefit analysis, as they pertain to possible non-compliance with prevailing federal laws and regulations.

Comment: A commenter suggested that the estimated annual volume of NOVs per year (10–20 NOVs) is too low and recommended that IRCC should plan for a higher volume of cases.

Response: The estimate of 10 NOVs in the first year and 20 NOVs in subsequent years is based on an analysis of historical trends and data from past IRCC investigations, where IRCC would anticipate meeting the evidentiary burden and ensuring procedural fairness, ultimately leading to the issuance of an NOV. Although these volumes are not high, the APC regime offers an effective and direct way to motivate compliance without resorting to expensive and time-consuming court proceedings.

Indigenous engagement, consultation and modern treaty obligations

An assessment of modern treaty obligations did not identify any modern treaty implications or obligations associated with the Amendments. The Amendments are not expected to impact Indigenous Peoples.

Instrument choice

Regulatory amendments were the only instrument considered because it is the only viable instrument to establish the APC regime for non-compliant and fraudulent individuals who provide immigration and citizenship services.

Regulatory analysis

Benefits and costs

An important first step in developing a cost-benefit methodology is establishing a baseline scenario against which options may be measured. For this analysis, the baseline scenario is one where an APC regime would not be implemented, contributing to the existing gap in regulatory tools, as IRCC cannot impose penalties and consequences on individuals who provide advice and representation for remuneration without authorization or counsel fraud and misrepresentation on their clients’ applications. The baseline scenario is then compared with the regulatory scenario, in which IRCC would introduce an APC regime, addressing the existing lack of tools for IRCC to sanction misrepresentation and unauthorized representation. The APC regime would allow for the issuance of penalties and consequences and provide the power to inspect individuals who are suspected of misrepresenting, counselling misrepresentation, or advising clients without authorization in the context of immigration and citizenship.

Compared to the version published in the Canada Gazette, Part I, the cost-benefit analysis has been updated to remove the monetized benefits associated with administrative monetary penalty revenues. This change reflects a methodological refinement to the treatment of penalty revenues in the analysis and results in revised monetized cost-benefit estimates. In accordance with the Policy on Cost-Benefit Analysis, taxes, levies and other charges constitute transfers from one group to another, and are therefore not considered to be compliance or administrative costs, including if intended as incentives to foster compliance and change behaviour. Correspondingly, the cost of paying a penalty, as well as the revenues to the Government of Canada generated through receipt of the penalty, are not considered costs nor benefits within the scope of the regulatory analysis, since they are outside the normal course of business, occurring only in instances of non-compliance.

The estimated costs of the Amendments are monetized for 10 periods of 12 months (2026 to 2035) and are expressed in 2023 dollars, while the benefits are described qualitatively. The Amendments come into force on the day they are registered. For further details regarding the methodology, a detailed cost-benefit analysis report is available upon request at the following email address: IRCC.APC-SCA.IRCC@cic.gc.ca. As the impacts pertain to penalties and consequences issued to those that contravene the law, no consultations outside of prepublication in the Canada Gazette, Part I, were conducted on the cost-benefit analysis (CBA) for the Amendments.

Costs to the Government of Canada are estimated at $13,826,575 PV over 10 periods. These costs are expected to be offset by the benefits of the Amendments, including a reduction in immigration and citizenship fraud and increased trust in Canada’s immigration and citizenship system.

Costs

Introducing the APC regime results in incremental costs to the Government of Canada. These costs will be incurred by IRCC. Although the RCMP and CBSA are involved in criminal investigations as related to enforcement of the CA and IRPA respectively, the regulatory amendments are not expected to impose any costs on them, as they will not be involved in IRCC’s APC regime itself.

During the prepublication period, stakeholders expressed concerns that the APC regime may discourage some immigration and citizenship professionals from taking on complex cases due to the risk of penalties. The analysis acknowledges the risk that practitioners may avoid cases perceived as high-risk or legally complicated to minimize exposure to penalties, potentially reducing access to representation for vulnerable clients with complex needs. Additionally, there is concern that increased caution among practitioners might lead to more conservative advice or reluctance to advocate vigorously for clients, which could negatively affect case outcomes. These risks, while important, must be balanced against the need to uphold the integrity of the immigration and citizenship system and deter unlawful or unethical behaviour. It should also be noted that the regime focuses on two specific violations — unauthorized practice and misrepresentation — neither of which is linked to the complexity of an application or situation.

Costs to the Government of Canada

The total costs to IRCC are estimated at $13,826,575 PV over 10 years. These include $1,795,758 PV in transition costs from developing IT functionality to issue penalties; training staff, drafting initial operating procedures, program delivery instructions and document templates; and preparing communications material related to the regime and the Amendments. Ongoing costs to IRCC are estimated at $12,030,817 PV and include costs for investigating possible violations, issuing and reviewing penalties, managing communications, reviewing requests from alleged violators, setting up penalty accounts, sending statements to violators, following-up to obtain missed payments, engaging in additional collection activities when needed, developing regime reports, and providing legal advice where needed.

Impacts on those who provide immigration and citizenship services

The implementation of the APC regime would impose monetary penalties on individuals who are found to have committed a violation, and in some cases, costs related to the request for a review of their penalty amount and/or a review of the facts of the violation. Penalty amounts per NOV range from $2,500 to $1.5 million, as listed in the “Description” section. Determining a precise number of NOVs that would be issued each period can be challenging, especially given the absence of historical data on NOV issuance, and that the Amendments introduce a new APC regime. For the purpose of this analysis, simplifying assumptions were made to estimate the costs of the Amendments. As such, it is assumed that the Amendments would result in approximately 20 NOVs being issued per period, except in period 1, when approximately 10 NOVs are assumed to be issued. The relatively low number of NOVs anticipated in the first year reflects timing constraints associated with the coming into force of the Amendments. Only conduct occurring after the regulations come into force would be subject to enforcement. As a result, given the time period needed to establish an evidentiary basis, there is a more limited initial number of violations that can occur, be identified, and proceed through IRCC’s compliance and enforcement processes to the point of issuing NOVs. This estimate is based on an analysis of historical trends and data from past IRCC investigations where IRCC would anticipate meeting the evidentiary burden and ensuring procedural fairness, ultimately leading to the issuance of an NOV.

Although the Amendments would impose monetary penalties on violators, penalty costs on violators do not have standing for the purpose of cost-benefit analysis. Penalties are a result of activities contrary to prevailing laws and regulations in Canada and are thus not included in the monetized costs. Similarly, some individuals may choose to make a request for a review of the violation or penalty if they feel there is an error in their case. IRCC acknowledges that individuals may incur costs as related to submitting evidence against a preliminary notice and requesting an NOV review. It is estimated that, in 75% of the cases, those accused of violations would incur costs to provide additional evidence in their defence. In the case of lawyers, they may assert by affidavit that they are unable to respond to a preliminary notice due to solicitor-client privilege. These activities would require time effort. IRCC acknowledges that individuals may incur costs related to these activities, estimated to range from $2,400 to $4,700. However, these costs would only have standing for the purposes of this cost-benefit analysis if they are attributable to Canadians and if a review is undertaken and the penalty is overturned. Otherwise, review request costs do not have standing for the purposes of this cost-benefit analysis, as they pertain to possible non-compliance of prevailing laws and regulations. The threshold for the issuance of a preliminary notice and an NOV will be high, with a strong emphasis on procedural fairness and evidentiary rigour. Only well-substantiated cases supported by sufficient evidence will be advanced, ensuring that enforcement actions are proportionate and reducing the likelihood that individuals who have not committed violations incur unnecessary legal or defence-related costs.

IRPA and the CA extend outside Canada’s borders. Most applications received by IRCC are from outside Canada. These applicants may be working with individuals providing immigration and citizenship services outside Canada, but those individuals are still subject to these two Acts, allowing IRCC to issue monetary penalties and consequences to individuals outside Canada. This APC regime also includes the publication of the violator’s name and business information on IRCC’s website. This could potentially have a significant impact on violators (whether inside or outside Canada), as public disclosure serves as a powerful deterrent and protection measure by publicly identifying those who violate immigration and citizenship laws, negatively impacting their professional reputation and credibility, including their ability to attract clients.

Benefits

Administrative penalties offer an effective and direct way to motivate compliance without involving expensive and time-consuming court proceedings. Administrative penalties widen the range of enforcement options available, allowing the flexibility to modify a response to specific compliance issues.

Implementation of a regime that imposes penalties and consequences for misrepresentation and unauthorized representation provides IRCC with additional tools to enforce compliance, other than referring all cases for criminal prosecution (which requires significant resources and higher evidentiary thresholds).

The introduction of this APC regime is expected to reinforce compliance and motivate behavioural change by those who provide unauthorized immigration and citizenship services, or who misrepresent clients in immigration and citizenship applications. The Amendments are also expected to increase public awareness of non-compliant or unethical individuals, as the names of businesses and individuals who are found to have committed a violation would be published on IRCC’s website, helping clients search a potential practitioner before requesting their services.

Cost-benefit statement
Table 1: Monetized costs
Impacted stakeholder Description of cost Period 1 Period 5 Period 10 Total (present value) Annualized value
Government of Canada Transition costs $1,795,758 $0 $0 $1,795,758 $255,676
Ongoing costs $1,374,001 $1,580,999 $1,580,999 $12,030,817 $1,712,918
All stakeholders Total costs $3,169,759 $1,580,999 $1,580,999 $13,826,575 $1,968,593
Quantified (non-monetized) and qualitative impacts

Positive impacts

Negative impacts

Small business lens

Analysis under the small business lens concluded that the amendments will impact Canadian small businesses; however, penalties and related dispute resolution processes are not considered administrative or compliance activities as described in the Policy on Limiting Regulatory Burden on Business. The great majority (99%)footnote 3 of licensed practitioners are estimated to be small businesses, so it is expected that most of the penalties issued as a result of the regulatory amendments would impact small businesses.

It is important to note that when a preliminary notice is issued, individuals may choose to provide additional information and evidence to counter the notice, which would require effort to produce and submit such information. Similarly, when an NOV is issued, individuals may request a review of their case, or in the case of lawyers, they may assert by affidavit that they are unable to respond to a preliminary notice due to solicitor-client privilege. These activities would require time effort. IRCC acknowledges that individuals may incur costs related to these activities, estimated to range from $2,400 to $4,700. However, these costs would only have standing for the purposes of this cost-benefit analysis if a review is undertaken and the penalty is overturned. Otherwise, review request costs do not have standing for the purposes of this cost-benefit analysis.

One-for-one rule

The one-for-one rule does not apply, as there is no incremental change in the administrative burden on business and no regulatory titles are repealed or introduced.

The regulatory amendments allow practitioners to request a review of their NOV, submit evidence to counter a preliminary notice, or in the case of lawyers, they may assert by affidavit that they are unable to respond to a preliminary notice due to solicitor-client privilege. These tasks may result in costs to those who provide immigration and citizenship services. However, information requirements in dispute resolution processes are not considered administrative or compliance activities as described in the Policy on Limiting Regulatory Burden on Business.

Regulatory cooperation and alignment

To assess whether there are opportunities for cooperation or alignment, IRCC identified jurisdictions that regulate the provision of immigration and citizenship advice and representation to identify possibilities for alignment. It was determined that regulatory cooperation or alignment with international or domestic partners is not feasible and would not achieve the desired policy objectives, since the target individuals are providing advice for the purposes of immigrating to Canada or advice related to Canadian citizenship, based on federal laws.

Aligning regulatory frameworks with those of other jurisdictions — whether provincial or international — would be incompatible with the structure and intent of Canada’s federal immigration and citizenship system.

International obligations

The Amendments do not impact any obligations in Canada’s international trade agreements.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA), a preliminary scan concluded that a SEEA is not required.

Gender-based analysis plus

The gender-based analysis plus (GBA+) assessment considered the effects on IRCC clients who rely on immigration practitioners and unauthorized individuals providing immigration and citizenship services. The APC regime is expected to have a positive effect on IRCC clients, including the hundreds of thousands of IRCC clients from all over the world who apply to its immigration or citizenship programs each year. These measures enable applicants to make informed decisions when selecting an immigration or citizenship practitioner by providing public access to the names of practitioners who have received NOVs. The APC regime would have a particularly positive impact on clients who are vulnerable due to language or cultural barriers and who rely extensively on those who provide immigration and citizenship services for navigating the application process.

Furthermore, it was determined that these regulatory amendments are not expected to negatively impact any group of persons disproportionately on the basis of identity factors such as gender, race, ethnicity, sexuality, religion and age. During consultations with stakeholders, no concerns were raised about disproportionate negative impacts to specific groups.

Implementation, compliance and enforcement, and service standards

Implementation

The proposed Amendments come into force on the day they are registered.

IRCC has completed the necessary IT updates to integrate APC functionality into processing systems. IRCC has also developed the preliminary notice, the NOV, and the notice of decision letter templates. Additionally, new training and guidance materials have been developed to ensure officers are well-informed, equipped with the necessary skills, and supported in conducting inspections, collection processes, and issuing penalties for non-compliance. IRCC has developed guidance material to explain the APC regime to the public. IRCC has also established a formal process for payment collection. A reviewer will be appointed by the Governor in Council before the first NOV is issued.

Compliance and enforcement

Inspections of those who provide immigration and citizenship services would be conducted when there is a basis to suspect non-compliance on client immigration and citizenship applications. Suspicion could originate from a complaint, an anonymous tip, information received from other government agencies, or patterns detected through routine monitoring and audits.

Individuals who are found to have violated one or more of the prohibitions on applications may be subject to administrative monetary penalties, up to a maximum of $1.5 million. Factors such as previous non-compliance and the impact of the violation would be taken into consideration when issuing administrative monetary penalties. Individuals found to be non-compliant will have their names and additional information about the non-compliance posted on a publicly available Government of Canada website.

The APC regime is an additional tool designed to complement existing measures that apply to the same regulated parties. Existing tools include professional discipline by regulators such as the College and provincial law societies, as well as criminal enforcement agencies such as the CBSA and the RCMP. These measures work together to ensure compliance, deter violations, and promote ethical conduct across the sector.

The APC regime has mechanisms in place to ensure procedural fairness for those who provide immigration and citizenship services. If non-compliance was identified during an inspection, individuals will be given a formal opportunity to provide additional information to demonstrate compliance or to justify instances of non-compliance.

Once an NOV is issued and the final decision is rendered, the individual will have an opportunity to request a review of that decision from a reviewer. Once the IRCC review process has been completed, the individual will be bound by the decision, but will be able to apply for leave to the Federal Court to commence an application for judicial review of the decision.

Contact

Tara Lang
Director General
Integrity Policy and Programs Branch
Immigration, Refugees and Citizenship Canada
Email: IRCC.APC-SCA.IRCC@cic.gc.ca